The proposed interim…

The proposed interim amendments to the ESA and the subsequent implementation of the proposed SCA is fundamentally flawed if economic, environmental, social and health sustainability for Ontarians is still a supposed foundational vision or goal of the Province. The proposed registration based development first approach will invariably not only cause undue harm to known species under duress but will also have negative impacts on other native species and natural systems that are necessary for supporting strong economy and healthy people.

The assertion of legislation like the ESA (EPA…) being draconian or too detailed in terms of requirements is flawed in that the need for such Acts only came to be because past Provincial approaches did not go far enough to ensure adequate protection and accounting of environmental, indigenous rights and other social considerations that invariably caused harm and negative impacts on economic activities, communities, people and the natural capital of the Province. Walkerton comes to mind.

Having a registration process whereby an individual or entity can good faith fill out an online form and start development in the absence of sound knowledge about what may or may not be present from an ‘endangered species’ perspective is the ultimate in gambling and unnecessary risk. At least with a permit based approach, the need for understanding available information by both the reviewer and proponent can stand a chance of a ‘sustainable’ venture. The risky registration process with subsequent development whether point source development or on a larger area or landscape level will both directly and indirectly hasten the loss of species under duress. Alarmist or not, collapse of natural ecosystems will occur as species disappear. Healthy natural ecosystems and environment are foundational for economic and social well-being. This is not a jargon statement but is a fact.

The proposed narrowing of the definition of habitat in the amended ESA and proposed SCA is ludicrous from a species protection perspective. The requirement to put blinders on only protecting site specific requirements of ‘endangered species’ (denning, dwelling…) although important, it will not contribute to protecting if range, breeding and reliant interactions with other biotic and abiotic dependencies are not taken into consideration. As written, the proposed approach will hasten annihilation. Of course maybe that is point of the new approach, profit at all costs.

Lastly, no longer requiring or establishing recovery strategies and/or action plans for ‘endangered species’ just adds to what will be a disaster for sustainability. Science is critical to manage the environment and policy-based decision making. This declaration of removal from the ESA is truly baffling. Comes across as a “not our problem “ approach which is very infantile. The opportunity for many interests from federal and provincial governments, indigenous and Métis peoples, economic interests, private sector, communities and science-based institutions to share, collaborate and harmonize on factual information to inform how development can occur respecting ‘endangered species’ is possible.

Understandably our Country and Province are under immense pressure to establish or ascertain self sustaining successful economies. Development will be a critical element to this but it needs to be done in a manner that is expeditious so long as it also well informed and strategic. It cannot occur in a “Wild West frontier “ mentality or we will end up in a disastrous state environmentally. Healthy planet, means healthy people and healthy economy. The proposed approach for the ESA and SCA is antiquated, has failed in the past and will fail the people of Ontario in the long run.